ML20205Q726
| ML20205Q726 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1984 |
| From: | Matthews P NRC |
| To: | Oliu W NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030033 | |
| Download: ML20205Q726 (14) | |
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/ f SSEP WRITEUP C0CUMENT CONTROL / ROUTE SHEET
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/O - 3 l Allegation Numbers 16 . 26 . AR _ EO . 51. 57 T9 Subject of Allegation ( h +ih' "f,vsde/rs O /Lue '
TRT Groip C#4 T/be, S
Author: c . e . h6 u ._3 This sheet will be initialed by each reviewer. It stays with all re' visions to the SSER writeup and serves as a reuting and review record. It will be filed in the
' work package when the writeup is published.
Draft Number 1
1 2 3 4 5 Draft t q-s 9- %e4 Author I Illk y,,7 0. d ,
Group Leader f/dHQ//1 V#rA' W1go. l Tech. Editor lJ41/% %ifm 7A/J Wessman/Vietti .V i J. Gagliardo f/
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- T. Ippolito / - _
Revision Number 2 3 4 5 Final 1 - .
Author -
Tech. Editor I Group Leade'r
,. J. Gagliardo g
T. Ippolito ,
Administrative -
Writeup integrated into SSER /h'1 Potential Violitions to Region IV Workpackage File Complete Workpackage Returned to Group Leader p) h(O
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Document NEme:
PARTS OF BNL-14, 25, ETCt Requestor's ID:
DEMCET01
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Author's Name:
Chet Poslusny -
Document Comments:
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, Draft 3 / CPSA Parts of BNL-14, 25, etc. .
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. October M , 1984 i <
SSER 4
- 1. Allecation Group: Protective Coatings Category No. Sa, (Inspection Reports) .
- 2. Allegation Number: Parts of AQO-14, 25, 49, 50, 52, 53, 57, and 59
- 3. Characterization: It is; alleged that: ,
In'spectionReports(irs')canbedispositiu.edbyanyone(AQ0-14b.)
Instead of writing NCRs, irs must be written as unsatisfactory (AQO-14b.)
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Nothing prevents items identified on unsatisfactory irs froni beccmin9 lost, and the problem is not being resolved (AQO-14b.)
A seal ccat was accepted by QC per'sonnel prior to the finish coat being applied when the seal coat should have been rejected (AQ0-25)\ '
Coating material is oversprayed into areas that were previously
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inspected,apracticethatisallowed,andiscommonplace(AQO-49).
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Coatings have been applied without the benefit of quality control inspection (Ag0-50 and 52).
QC inspectors denied opportunity of writing Request fhr I'nformation
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onClarification(RFIC) ( A'Q0-53)
Coatings were applied over filth (AQO-57).
SubstandardcoatingswereacceptedbyQCinspectors(AQ0-59). .
- 4. Assessment of Safety Significance: The implied safety concern of these allegations is that inadequate inspection reports couldresult in failure to demonstrath that all protective coatings inside the reactor containment building were applied in accordance with specified requirements. An evaluatiori of the significance of this safety concern is reported in (later). The team evaluation of the quality assurance aspec'ts of the allegations related to coating inspection reports as f characterized above is discussed below. -
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I To address the allegations concerning disposition of irs for protective coatings, the TRT conducted a generic examination of the IR system in l this area. The TRT reviewed TUGC0 Procedure CP-QP-18, which indicates i I
that irs are the primary method used to document satisfactory and unsatisfactory coating inspections. The TRT examination of many irs \
shows tirat coating problems usually occur during onsite applications and inspection. A time when repairs can easily be identified, documented, and made through the existing IR system. irs that document problems that
! cannot be corrected using standard repair procedures are then documented
) by an NCR. Accordingly, as discussed below in AQ0-14 the TRT finds the existing IR system and its implemantation to be satisfactory.
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Improper Use of irs: (AQO-14b .
In assessing the allegations that comprise AQ0-14, the TRT interview QC personnel and found that QC per's'olnnel were discouraged from writ [ CRs by 1
Procedure QI-QP-11.4-5, Revision 22. Paragraph 3.9 of this revision states: " Nonconforming conditions shall be reported on an IR in .
accordance With CP-QP-18.0." TUGC0 Procedure CP-QP-18.0, Revision 12, (7/19/83), lists three methods by which irs are closed: (1) all items are satisfactory, (2) all unsatisfactory items have been' repaired and
. reinspected and found sati,sfactory, or (3) an NCR has been issued for unsatisfactory items.
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The TRT reviewed QI-QP-11.4-5, Revision 22, which was in effect during the perialioftheallegations,andfoundthatParagraph3.9wasmisunderstood by some inspectors. However,DI-QP-11.4-5referencedCP-QP-18.0 Revision.
12, which in the opinion of the TRT contained adequate methods for closing an IR. Revision 29 of QI-QP-11.4-5 clarifies when NCRs sihould be prepared. Discussions with QC inspectors on the current revision of QI-QP-11.4-5 (Revision 29) indicate that they are satisfied with this 1 revision and understand it. TRT's inte'rview with the QC inspectors indicated that even with the old revision of QI-Q'P-11.4-5, QC did not \
2 ignore nonconforming conditions. Review of site procedures by the TRT indicates that irs are not dispositioned by anyone. The only difference 5
betweenRevision12andRevision20(thecurrentrevisionissueinSeptember 1984) of CP-QP-18.0 is that Revision 20 specifies a DCA may also be issued which makes the unsatisfactory condition acceptable.
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- The TRT reviewed the TUGC0 Paper Flow Group (PFG)? which issues protective coating (PCs) inspection .eport numbers and tracks all
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incompleted work packages. This system was initiated'Janu&ry 1,1984.
PFGcollectedallunsatisfactoryIRspriortoJanuary1984anddeveloped work packages which document all coating work, including repairs in a given plant area. The TRT performed a sample review of abut lu0 .
unsatisfact6ry irs issued between December 1, 1982, and January 1, 1984 by which time most coating work except for repairs was completed in Unit
- 1. TRT found that these unsatisfactory IR's had been or were being properly processed and tra,cked. Work packages and irs were updated on a daily basis by entering deficient, discrepant, and completed work, '
packages on a computer list." The implementation of the PGF system and protective coatings work packages prevented items identified on an IR from becoming lost and not corrected. The PFG system appears to' work effec-
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tively.
Unacceptable Seal Coat: (AQ0-25)
Allegation AQ0-25 concerned a seal coat on the liner plate in Unit 1 outside the Skinner Pump Room bei,ng accepted when it should have been rejected. The alleger states that stains on the' liner were, in his opin' ion, unaccept-able per procedure.
TRT interviewed the QC supervisor involved who indicated that the stains were acceptable by Procedure QI-QP-11.4-26, Revision 6. He stated that
w the liner was wiped with solvent and water, that the.QC inspector involved appeared to be satisfied with the work, and that no pressure was placed on the QC inspector for him to accept the work'as done.- Review of -
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the relatad irs by TRT indicated that the alleger, in fact, did sign th'e f IR as satisfactory. The TRT could.not ver'ify that the QC inspector was coerced based on the fact that his irs were signed as " satisfactory. .
(Coercion of QC inspectors is the subject of a separate investigation by the NRC Office of Investigation.) The TRT finds that sta' ins on organic
. coatings not removed with , water and solvent wiping are acceptable. A TRT observation of the area indicated that it had been topcoate,d and
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accepte'd. -
Overspray: (AQO-49) .
A Allegation AQO-49 involves' alleged overspray into areas that ,had previous 1y been inspected which had been allowed and was commonplace..
The TRT review of coating procedures for concrete and structural steel found that overspray/ dry spray were ade'quately addressed in the procedure revisions ~ made before, during, and after the time' frame of the allegation's. '
The TRT -then , randomly interviewed coatings QA/QC inspectors, each of whom .-
stated that when overspray was encountered, it was corrected in accordance with applicable QC procedures. - -
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Excessive overspray of primer, if not corrected, can cause adhesion problems when a final coat is applied; however, the TRT review of QC and construction procedures (QI-QP-11.4-5, 4-10, 4-27, and AS-31) indirated, c
that overspray for primer was s'u'pposed to be removed, while a minor amount of overspray was acceptable for the final coat. Small amounts of the final or topcoat overspray pose no adhesion problems. It is not uncommon .
for overspray to occur on adjacent areas during spray applications and CPSES coating procedures and practices adequately addressed this issue.
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. Coatings Applied Without-QC Inspection: (AQ0-50 & 52)
Allegations AQO-50 and 52 address protective coatings applied withcut the benefit of QC inspections.
The TRT reviewed several NCRs and found documented instances in'which -
coatings had been applied without appropriate QC inspection. However, the alleger gave only general locations affected by this allegation, such as a hanger located on the steel liner, rather than a specific location. TRT made four attempts during August 1984 to contact the alleger by telephone for more specific information. Messages were given to a relative and co-worker of the alleger for the alleger to call 'TRT collect. The alleg'er
- never responded. TRT attempted to obtain a forwarding address from the post office but had no success.
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7 The TRT review of NCRs indicated that the existing QC inspection program was working in that it documented and identified nonconformances which had not received QC inspections. All areas identified weie reworked or dis- rus sie r nor ta on positioned in accordance to siti procedures.hrocedures CCP-30, CCP-30A, ' 9 U U*
g.t U'hr and CCP-4'O all specify " hold points" for the craft personnel where an ,
inspection must be performed during inprocess application of protective ,
Although there have been incidents of coatings being applied without QC
. inspections,.there are ade,quate procedural measure.s established to minimize this from recurring.
QC Inspectors Denied Opportunity of Writing Requests for Information or Clarification (RFIC)(AQO-53) -
e Allegation AQ0-53 alleges that QC inspectors were not to write Requests for Information or Clarification. TRT review of this allegation'indi-QC-cates that for a short period of time a former protective coatingsAsuper-visor did verbally instruct QC inspectors not to write RFICs. The verbal directive was then. rescinded by QA/QC m'anagement. Interviews with present QCinspectorsbyTRTindicatethattheyhavenotbeendeniedorverballfs
- told not- to write RFICs. Review of many RFICs by TRT after this incident indicate that QC inspectors are writing RFICs. RFICs are written by QC inspectors for clarification of a procedure / specification or any other question he/she may have on an item.
t TRT concludes that the allegation is true. However, RFICs have no pro-cedural requirement, therefore not violating any requirement. There is I
no safety significance to this issue. - -
Coatings Aeplied Over Filth: (AQ0-57)
Allegation AQ0-57 alleges that at the'860-ft elevation of Unit 2, coating was applied to surfaces in the room directly off the elevator which were covered with filth, weld spatter, tobacco juice, and other
. unsuitable material. -
The TRT located the room in question and observed that repair work was in progress on the unacceptable area. The area was in Room #163, Rod Position Indication (RPI), elevation 860, Unit 2 Reactor Building, a location documented by NCR-C84IO812 and PC 45291 and attachments.
Acceptance of Substandard Coatings:
Allegation AQ0-59 alleges that QC inspectors accepted substandard coating
, on the liner plate below and above the polar crane rail at azimuth 270*
to 0* in the Unit 1 containment building. The TRT examined all \
1 protective coating (PC) inspection reports related to the area from
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azimuth 270* to 0* between the 905 and 940-ft elevations on the I containment steel liner plate. The review indicated that many irs were {
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9-prepared that noted unsatisfactory conditions, which were later corrected.
?!one indicated that,QC inspectors accepted substandard coatings. The irs are well documented and also reference the satisfactory irs.
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Only one of the QC inspectors involved in writing these irs was still working at Comanche Peak. TRT interviewed the remaining QC inspector, but he gave'no indication that QC inspectors had accepted substandard work.
The TRT also interviewed nine current on-the-job QC inspections at CPSES, all of whom stated that QC inspectors do not accept substandard work.
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- 5. Conclusion and Staff Positions: Based on the TRT review of the TUEC (
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inspect' ion report system and their implementation of it, as well as on the TRT investigation of alleged improper use of irs, unacceptable seal coat, overspray, coatings applied without QC inspections, coatings l
applied over filth and acceptance of substandard coatings, the TRT concludes that reviews of all issues involved indicated in each case that-proper documents existed and corrective action was initiated.
Allegations AQO-50, 52, and 57 were substantiated, but had proper documentations and appropriate corrective action. The TRT concludes that these allegations have neither safety s'ignificance nor generic implications. \
- 6. Actions Recuired: 6cc. Codi ac s $5PK- 7 [Tec mi " A du a s B e. Cd for anner r5E%m in on M 5 p Itc " bk e uNs .
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- 8. Attachments: None.
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- 9. Reference Documents: -
- 1. CP-QP-18.0, " Inspection Reports," Revision 12(7-19-83), Revision 13 (11-18-83), Revision 11(5-19-83), and Revision 20 (8-09-84). .
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- 2. QI-QP-11.4,26, " Inspection of Steel Substrate Primer Repair and Seal and Finish Coat Application and Repair," Revision 29 (5-04-84),
Revision'22 (9-23-83),, Revision 23 (10-07-83). -
- 3. QI-QP-11.4-26, :Inspecjion of Steel Substrate Surface Preparation, Primer Application, Primer Repair, Seal and Finish Coat Application and Repair," Revisions 0, 4, and 6.
- 4. QI-QP-11.4-27, " Inspections of Concrete Substrate Surface Preparation and Coatings Application and Repair," Revision 0 (12-29-83), Revision 4 (6-12-84) Revision 5 (7-06-84), Revision 6 (7-11-84).
- 5. CCP-30A, " Coating Steel Substrates Inside Reactor Building and \
- Radiation Areas," Revision 4, March 4,1984.
- 6. CPP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas," Revision 12, March.4, 1984.
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- 7. CCP-40, " Protective Coating of Concrete Surfaces," Revision 7, March 4, 1984.
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- 8. AS-31, " Protective Coatings'," Revision 2, March 15, 1984. '
- 9. NCR-C84-0182. .
- 10. PC #45291.
.11. PC f45570. ,.
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- 10. This"s'tatement prepared by:.
, Claude Johnson Date Reviewed by: -
P. R. Matthews Group Leader Date .
Approved by:
Project Di' rector Date x.
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